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acquired additional agreed agreement allowed amount applied assets bank basis bonds capital cash cent claimed Commissioner complete computed contends contract contributions corporation cost Court death decedent December decision deduction deficiency depreciation determined distribution district earnings effect employees ended entered entitled evidence excess profits expenses facts filed FINDINGS fiscal follows funds gross held holding husband income tax interest Internal Revenue Code invested involved issue January July June liability loans loss March meaning months notice operating opinion organized paid parties partnership payment period petitioner petitioner's present principal prior purchase question reason received record referred reported represented resident respect respondent result salary securities shares stockholders tax return taxable taxpayer term tion transaction transfer trust United wife York
Page 915 - States, who establishes to the satisfaction of the Commissioner that he is a bona fide resident of a foreign country or countries during the entire taxable year, amounts received from sources without the United States (except amounts paid by the United States or any agency thereof) if such amounts constitute earned income as defined in...
Page 928 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 915 - EXCLUSIONS FROM GROSS INCOME In addition to the items specified in section 22 (b), the following Items shall not be Included In gross Income and shall be exempt from taxation under this chapter : (a) EARNED INCOME FROM SOURCES WITHOUT THE UNITED STATES.
Page 851 - And the relation of master and servant exists whenever the employer retains the right to direct the manner in which the business shall be done, as well as the result to be accomplished, or, in other words, "not only what shall be done but how it shall be done.
Page 927 - LOSS. (a) GENERAL RULE. — Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 111, shall be recognized, except as hereinafter provided in this section.
Page 826 - ... of such a nature that an extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily in the United States, he becomes a resident, though it may be his intention at all times to return to his domicile abroad when the purpose for which he came has been consummated or abandoned.
Page 17 - Intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death (1) the possession or enjoyment of, or the right to the Income from, the property...
Page 351 - Article 6 (Section 17201 and following) which consist of expenses paid or incurred by the taxpayer, in connection with the performance by him of services as an employee, under a reimbursement or other expense allowance arrangement with his employer.
Page 636 - The absolute ownership of personal property shall not be suspended by any limitation or condition whatever, for a longer period than during the continuance and until the termination of not more than two lives in being at the date of the instrument containing such limitation or condition: or if such instrument be a will, for not more than two lives in being at the death of the testator.